ML20094A384

Forwards Testimony of Rj Hippert,Df Taylor,Ep Klynoot, Rl Reber,Hw Farrel,Fn Starasinic,Rc Furrer,Ma Reilly, Ma Worman & SA Runkle on Limerick Ecology Action Offsite Emergency Planning Contentions.Related Correspondence

ML20094A384
Person / Time
Site:	Limerick
Issue date:	11/01/1984
From:	Ferkin Z PENNSYLVANIA, COMMONWEALTH OF
To:	Cole R, Harbour J, Hoyt H Atomic Safety and Licensing Board Panel
Shared Package
ML20094A385	List: ML20094A384 ML20094A393 ML20094A405 ML20094A416 ML20094A432 ML20094A582 ML20094A611 ML20094A639 ML20094A650
References
CON-#484-944 OL, NUDOCS 8411060401
Download: ML20094A384 (2)

Text

l g RELATED COMESTCNDU(Og

, COMMONWEALTH OF PENNSYLVANIA GOVERNOR'S ENERGY COyNCILTl-5 P2:14 P.O. BOX 8010 1625 N. FRONT STREET o

HARRISBURG. PENNSYLVANIA 17105

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785022o November 1, 1984 Helen F. Hoyt Dr. Richard F. Cole Administrative Judge Administrative Judge Atomic Safety and Licensing Board Atomic Safety and Licensing U.S. Nuclear Regulatory Commission Board Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Washington, D.C.

Dr. Jerry Harbour Administrative Judge Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 t RE: Limerick Nuclear Generating Station, Docket Nos.

50-352, 50-353 OL

Dear Administrative Judges:

In accordance with the Board's Orders dated August 15 and October 9, 1984, the Commonwealth of Pennsylvania hereby files testimony on Limerick Ecology .'u: tion (LEA) and City of Philadelphia offsite emergency planning contentions as admitted and specified in the Board's Orders dated April 20, September 24 and October 19, 1984. The testimony filed is complete except as explained in detail below. All reference materials not included with this testimony should already be in the hands of the parties.

The Commonwealth intends to offer as witnesses all persons whose written direct testimony is filed today. The Commonwealth intends to offer as an additional witness on Contentions LEA-ll and LEA-15 Mr. Don Bryan, Deputy Secretary for Local and Area Transportation, Pennsylvania Department of Transportation.

The Commonwealth's testimony filed today is complete in all but one respect. In addition to the testimony and witnesses heretofore identified, the Commonwealth intends to sponsor the testimony of Timothy S. Campbell, Director, 8411060401 841101 PDR ADOCK 05000352

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c'- . November 1, 1984 l Page two .

Department of Emergency Services, Chester County on several of LEA's contentions.. Mr. Campbell is preparing written direct testimony on those contentions; however, for reasons unknown to the Commonwealth, his testimony has not been completed in time to meet the Board's November. 2 deadline.

In view of the nature of many of LEA's contentions, the Commonwealth believes Mr. Campbell's testimony will contribute significantly to the record in this proceeding, and that the parties should have the benefit of reviewing his written direct testimony prior to the hearing. The Commonwealth understands that Mr. Campbell's testimony will be available for review by the State later today, and could be filed with the Board andLparties early next week. The Commonwealth therefore hereby~ moves for permission to file out of time the written direct testimony of Timothy S.

Campbell. Cf. 10 C.F.R. 2.743 (b) (allow introduction of written testimony not served by prefiling deadline if parties have reasonable opportunity to examine it).

Very truly yours, L. . ! V Zori G. Ferkin

) Assistant Counsel (717-783-0225)

Enclosures CC: Service' List

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